SMETA, amfori BSCI and WCA Audits: What Auditors Check on Hours, Overtime and Attendance Records (India)
In a social audit, working hours are tested mostly on paper. The auditor pulls three months of time and wage records for a sample of workers, one of them your peak month, and checks them against production, shipping and worker interviews. Most hours findings come from records that don't agree with each other, more than from any single long day.
By the Mama Editorial Team, for owners of Indian export units who face SMETA, amfori BSCI or Intertek WCA audits through their buyers. Audit points come only from Sedex, amfori, ETI or Intertek documents; legal points from the Labour Codes and Rules. Not legal advice.
Key takeaways
- Two rulebooks apply. SMETA audits every requirement against local law and the ETI Base Code, and "the higher standard always prevails". In India that means you pay overtime at twice the wage under law, and you keep total hours within 60 a week under the Base Code.
- Plan for 12 months of records. Sedex expects 12 months of records to be available before an initial audit. Auditors then review at least three: the most recent, a peak and a low-season or random month (Sedex's Minimum Requirements v1.2, April 2026, copy published by the audit firm VWA).
- Manual registers need real times. Auditors accept manual attendance only with actual time-in and time-out, signed by workers once per pay period. Ticks don't count.
- amfori weights hours heavily. Of the four questions in amfori BSCI's Decent Working Hours area, three are "crucial" (overtime, daily breaks, one day off in seven). According to amfori, "in 2025, 80% of amfori BSCI-audited factories failed to meet working hours requirements" (all countries, not India alone).
- Inconsistent records cost you twice. Where production, payroll, shipping and hours records disagree, the auditor raises a finding because compliance can't be verified. Falsified records are treated as a serious non-conformance.
- Cameras are not a requirement in any audit document we read. Aggregate floor activity helps you check your registers before an auditor does.
The rulebook: law first, then the code, and the stricter one wins
SMETA (Sedex). The current methodology is SMETA 7.0, released in June 2024. It audits against the ETI Base Code plus local law. A gap against Indian law is a non-compliance. A gap where you meet the law but miss the Base Code is a non-conformance. Findings are graded Business Critical to Minor; there is no pass or fail.
The ETI Base Code, clause 6 sets the hours rules:
- contracted hours of no more than 48 a week, excluding overtime;
- all overtime voluntary, paid at a premium the Code recommends be at least 125%;
- total hours in any 7-day period "shall not exceed 60", except under clause 6.5, where all of these must hold: national law allows it, a freely negotiated collective agreement allows it, health and safety safeguards are in place, and exceptional circumstances (unexpected peaks, accidents, emergencies) apply;
- at least one day off in seven.
amfori BSCI. The Code of Conduct (2021) commits suppliers to no more than 48 standard hours a week. Overtime has to be "exceptional and voluntary", paid at a minimum of 125%, and never beyond the limits in national law. Workers get daily rest breaks and one day off in seven. The audit has 81 questions across 13 Performance Areas, each rated A–E. Performance Area 6 (Decent Working Hours) has four questions, and three of them are crucial. Fair Remuneration (PA 5) tests wages and deductions. A C rating or below can trigger a follow-up audit and brings the next full audit forward to one year instead of two.
Intertek WCA. Intertek's public pages list "Wages & Benefits, Working Hours" and "Documentation and Records" among the areas assessed. The detailed protocol isn't public; ask your auditing office for the checklist.
Indian law. The OSH Code took effect on 21 November 2025. It limits a worker to 8 hours a day and 6 days a week. Overtime needs the worker's consent and is paid at twice the rate of wages, which is basic plus DA, not gross pay. For a factory, your state makes the working rules on spread-over, breaks and the quarterly overtime ceiling. Where your state hasn't notified its own rules under the Code, its old factory rules broadly continue during the transition. The Central OSH Rules set 144 overtime hours a quarter for central-sphere establishments. Check your state's figure.
So an Indian unit lives with four limits: 48 normal hours, overtime at 2× (basic + DA), your state's overtime cap, and the Base Code's 60 total hours a week.
How an auditor actually tests hours
Sedex's Minimum Requirements bind SMETA auditors. We found no public copy on sedex.com; the link is a copy published by the audit firm VWA. What matters for your time office:
Timing. Audits happen when at least 60% of the peak workforce is present and the site is in full operation, not in the low season. Sedex's opening-meeting checklist (SMETA 7.0 Auditor Manual, Annex 5, VWA copy) has the auditor confirm your peak production periods and sample hours from them.
Which records. 12 months must be available for an initial audit (3 if the site is new); for a periodic audit, at least 3 months since the last one. Records missing without a legitimate reason are recorded as a non-conformance.
How many workers. The file sample grows with headcount:
| Workers on site | Worker files reviewed | Wage + hour records (× 3 months) |
|---|---|---|
| 101–500 | 26 | 78 |
| 501–1,000 | 42 | 126 |
| 1,001–2,000 | 52 | 156 |
Source: Sedex Minimum Requirements v1.2, auditor-day table.
Wage and hour months should match. Where a local waiver allows annual overtime hours, the auditor also checks 12 months of hours for at least five workers.
Triangulation. Evidence is cross-checked across documents, interviews and the site tour. On hours, the guidance names the records compared: "production records, payroll records, shipping records and working hours records". If March's register shows no overtime but March's shipments couldn't have been made in 8-hour days, that gap is a finding.
Interviews cover different shifts, every pay grade, and workers whose records show specific issues.
The non-conformities the guidance itself points at
Limited to what the Sedex, amfori and ETI documents name:
- Total hours above 60 in a 7-day week, usually in the peak month, even when every overtime hour was paid at 2×.
- No day off in seven days during a dispatch push.
- Overtime that isn't voluntary, for example a standing instruction that the line stays until the target is met. amfori asks for overtime to be "exceptional and voluntary".
- Overtime paid below the legal rate, for example 2× on basic only, or a flat allowance (a non-compliance against Indian law).
- Piece-rate pay that doesn't reach the minimum wage within standard hours. amfori's Code says this explicitly.
- Deductions not authorised by law. Both amfori (PA 5, a crucial question) and the ETI Base Code bar them.
- Manual registers with ticks instead of in/out times, or not signed by workers each pay period.
- Records that disagree with each other: production against hours, payroll against attendance, gate logs against overtime registers. The same Annex 5 checklist says Sedex members would rather work with a site on excessive overtime than see "hours of work could not be verified" because of inconsistent records.
Sedex states that members "will likely consider falsified or withheld information as a serious non-conformance". Honest records of 58 hours in a peak week beat records of 48 that nobody believes.
Keeping your records consistent under the Labour Codes
The Central OSH Rules (r.72, binding central-sphere establishments) show the Code-era register set: an employee register, an attendance-register-cum-muster-roll, and a register of wages, overtime and deductions, kept electronically or otherwise and preserved for five years. Your state's forms may differ. Then build these habits:
- One time source. Biometric or card punches feed attendance, overtime and payroll. The Model Standing Orders, 2026 allow attendance by ID card or biometrics at the start and end of the shift.
- Overtime consent recorded per occasion, signed and dated, not once in the appointment letter.
- A weekly 60-hour check on every worker in peak months.
- A monthly reconciliation of output against recorded hours, line by line.
- Overtime rounding by your state's rule. The Central Rules count 15–30 minutes as half an hour and over 30 as a full hour.
Our overtime cost calculator handles the 2× arithmetic, and Can Your Sewing Floor Take a 50,000-Piece Order? covers capacity from SAM.
Worked example: does March's output fit March's register?
The auditor's production-against-hours check, done by you first. Every number is an assumption; use your own SAM, efficiency and your state's current minimum-wage notification.
Assume: one sewing line, 40 operators, 26 working days. The register shows 8-hour days and no overtime. The style SAM is 20 minutes, and 16,000 pieces were packed in March. Wages (basic + DA) are assumed at ₹15,600 a month. So the daily rate is ₹600 (1/26), the hourly rate is ₹75, and the overtime rate is ₹150 an hour at 2×.
| Step | Line efficiency 55% (line's usual) | Line efficiency 50% |
|---|---|---|
| Standard hours earned (16,000 × 20 min ÷ 60) | 5,333 h | 5,333 h |
| Operator-hours needed (÷ efficiency) | 9,697 h | 10,667 h |
| Operator-hours on register (40 × 8 × 26) | 8,320 h | 8,320 h |
| Hours the register doesn't explain | 1,377 h | 2,347 h |
| Per operator per working day | ≈ 1.3 h | ≈ 2.3 h |
| Implied weekly total (48 + 6 × daily OT) | ≈ 56 h | ≈ 61.5 h |
| Cost to record and pay it at ₹150/h | ≈ ₹2.07 lakh | ≈ ₹3.52 lakh |
At 55% the gap is a records problem: the work fits inside 60 hours, so record the overtime, take consent and pay ₹2 lakh a month on this line. At 50% it is a capacity problem: even fully paid, the hours break the 60-hour line, and you need more operators, another line or a different promise to the buyer. amfori's own guidance names capacity planning and short-notice order changes as root causes of long hours.
Where cameras help, and where they don't
None of the documents we read requires CCTV: Sedex's Minimum Requirements and Annex 5, the ETI Base Code, and amfori's Code and rating guide. (Intertek's full WCA protocol isn't public.) Sedex asks auditors to photograph non-compliances and infrastructure, but the pictures must "not infringe privacy or data protection requirements" and workers' faces and names must be obscured. Don't install cameras "for SMETA".
Existing cameras can give an aggregate view: whether a line was active after the shift bell, how many stations ran at 7:30 pm, whether the floor worked on the weekly off-day. It is the auditor's cross-check, run daily, so gaps surface while you can still fix the register, consent and pay.
What video cannot tell you:
- Who worked the extra hour, or whether they agreed to it. Consent is a signed record, not a picture.
- Whether the overtime was paid at 2× (basic + DA). Only payroll shows that.
- Hours worked off the floor: home-working, a subcontractor's unit, or a loading crew outside the frame.
- Anything in toilets, changing rooms or rest areas. Cameras don't belong there.
If you use footage at all, keep it to line-level counts, give workers the DPDP notice, and never rank individuals; per-worker tracking undermines discipline more than it fixes it.
Where Mama fits
Mama reads the cameras a plant already has and sends the owner a short note each morning about the machines and lines: which ran past the shift end, which sat idle, and where hours leaked. It watches machines and flows, not named people, so evening running is a line-level fact to check against your overtime register. Mama doesn't produce audit evidence or replace your registers. Mama can draw a camera plan for the lines that run past the shift bell. Leave an email or phone in the form below.
FAQ
Does SMETA or amfori BSCI require CCTV in the factory? Not in the Sedex, ETI or amfori documents we read. If someone says "CCTV is mandatory for SMETA", ask for the clause.
How many months of attendance and wage records will a SMETA auditor ask for? Twelve months must be available for an initial audit (three if the site is new). The auditor reviews at least three of them, including your peak month, for a sample sized by headcount.
Is the ETI 125% overtime premium enough in India? No. SMETA applies the higher standard, and Indian law requires twice the rate of wages (basic plus DA). The 125% is only a Base Code recommendation.
Can we keep a manual muster roll? Sedex auditors accept manual attendance records if they show actual time-in and time-out and are signed by workers once per pay period. Ticks or symbols aren't accepted. Your state's rules decide the register format.
What happens if our peak month exceeds 60 hours a week? It is a Base Code finding even if the overtime was paid and lawful, unless every clause 6.5 condition is met. An honest record leads to a corrective action plan; a hidden one risks being treated as falsification.